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Insp Rept 50-445/85-06 on 850301-0430.Violation Noted: Procedure MDA-201 Did Not Provide Appropriate Instruction for Electrical & Mechanical Maint & Failure to Provide Procedure for Broken Seal Ring on Reactor Coolant Pump
	ML20133E966
Person / Time
Site:	Comanche Peak
Issue date:	05/29/1985
From:	Hunnicutt D, Kelley D, Will Smith; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	;
Shared Package
ML20133E934	List: ML20133E931; ML20133E951; ML20133E966;
References
	50-445-85-06, 50-445-85-6, NUDOCS 8510100079
	Download: ML20133E966 (9)
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APPENDIX B

U. S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-445/85-06 Permit: CPPR-126:

Docket: 50-445 Category: A2

Applicant: Texas Utilities Electric Company (TVEC)

Skyway Tower

400 North Olive Street

Lock Box 81

Dallas, Texas 75201

Facility Name: Comanche Peak Steam Electric Station (CPSES) Unit 1

Inspection At: Glen Rose, Texas

Inspection Conducted: March 1 - April 30, 1985

Inspectors: # C f8

M/ D. L. Kelley, Senior Resident Reactor Date

i Inspector (SRRI)

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W. F. Smith, Resident Reactor Inspector

s/ules

Date

(RRI)

Approved: Y}! snuienS $.Y ?5

D. M. Hunnicutt, Section Chief, Ddte /

Reactor Project Section B

Inspection Summary

Inspection Conducted: March 1 - April 30, 1985 (Report 50-445/85-06)

Areas Inspected: Routine, unannounced inspection of (1) Preoperational Test

Results Evaluation; (2) Independent Inspection Findings; (3) Followup on Open

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I' DETAILS

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1. Persons Contacted

Applicant Personnel

8. R.L Clements, Vice President, Nuclear Operations

J. C. Kuykendall, Manager, Nuclear Operations

C. H. Welch, Site Quality Assurance (QA) Supervisor

J.' C. Smith, QA

R. 8. Seidel, Operations Superintendent

H. A. Lancaster, Startup QA Specialist

J. M. Ward, Startup QA Specialist

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R. R. Wistrand, Administration Superintendent

R. A. Jones, Manager, Plant Operations

T. Gosdin, Support Services Superintendent

D. W. Braswell, Engineering Superintendent

G. D. Smith, Startup Manager

M. R. Blevins, Maintenance Superintendent

D. E. Deviney, Operations QA Supervisor

Denotes those present at exit interview.

The NRC inspectors also interviewed other applicant employees during this

inspection period.

2. Preoperational Test Results Evaluation ,

Lt. J The NRC resident inspectors conducted an inspection of preoperational test

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data packages which had been completed, approved by the Joint Test Group

(JTG), and placed in the station permanent records storage facility. The

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objectives of this inspection were to:

c' Assure that the appitcant is performing an adequate evaluation of

test results;

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o' . Assure that all test data are either within previously established ,

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acceptance criteria, or that deviations are properly dispositioned,

_ Evaluate the adequacy of the applicant's methods for correcting

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deficiencies and for retesting, if necessary; .

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o Evaluate the adequacy of the applicant's administrative practices in

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maintaining proper test discipline concerning test execution, test

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a'lteration, and test records; and

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o Verify that the applicant is following his procedures for review,

evaluation, and acceptance of test results.

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The inspection of each preoperational test package consisted of:

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_o A review of all test changes to verify that, (1) each change was

approved in accordance with pertinent administrative procedures;

(2) the procedure was annotated to identify test changes; (3) the

test change had been completed if it entailed specific actions; and

(4) none of the changes altered the basic objectives of the test,

o A review of all test deficiencies to verify that, (1) each had been

resolved, that the resolution had been accepted by appropriate

management and the JTG, and that retest requirements had been

completed; (2) any system or process changes necessitated by a test

deficiency were properly documented and reviewed.

o A review of the test summary and evaluation to ensure that, (1) the

System Test Engineer (STE) evaluated the test results and signified

that the testing demonstrated that the system mot design

requirements; (2) the applicant specifically compared test results

with established acceptance criteria.

o A review of the " official test copy" of the test procedure to verify

that, (1) data sheets had been completed (10% minimum sample);

(2) all data were recorded, where required, and were within

acceptance tolerances (10% minimum sample); (3) all test deficiencies

identified were noted and had received appropriate reviews and

evaluations; and (4) individual test steps and data sheets have been

properly signed and dated.

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o A review of QA involvement to verify that, (1) QA/QC witness and hold ,

points were observed where called for; (2) preoperational test

packages were audited as required by administrative procedures.

o Verification that the test results have been approved by the

applicant's JTG and that the review and approval is documented as

required by administrative procedures,

a. The following completed preoperational test data packages were

reviewed by the NRC inspectors, with no comments, and have met the

inspection attributes listed above:

(1) ICP-PT-64-02, " Reactor Protection System," Revision 0.

(2) ICp-PT-64-02, RT-1, " Reactor Protection System - Retest 1,"

Revision 0.

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f(3) .,1CP-PT-64-02, RT-2, " Reactor Protection System - Retest 2,'.'.

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L' ~ Revision O.

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Revision 0. '

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1(5) '1CP-PT-37-01, " Auxiliary Feedwater System (Motor Driven),"

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Revision 0.

(6) ICP-PT-37-01[ RT-1, " Auxiliary Feed Water System (Motor Driven)

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Retest-1," Revision 0.

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4 (7) ICP-PT-37-03, " Auxiliary Feedwater Turbine Driven Pump,"

Revision O. ,

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(8) .ICP-PT-37-03, Redo, " Auxiliary Feedwater Turbine Driven Pump '

4 Redo," Revision O.

.(9) ICP-PT-02-12, RT 1, " Bus Voltage and Load Survey, Retest-1,"

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Revision 0 (phase I & II).

b. The following completed preoperational test data packages were

, reviewed by the NRC resident inspectors, and have met the inspection

attributes listed above, except as described in the following

comments:

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(1) ICP-PT-34-01, " Main Steam Isolation Valves" (MSIV), Revision 1.

The NRC inspector noted that only MSIV control circuit :

operability had been successfully tested by this procedure. The

procedure was originally intended for operationally testing the

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valves as well as the control circuits; however, due to

eq, extensive failures and repairs, it was necessary to defer the

gp' testing of the MSIVs and MSIV bypasses (MSIVBV) from the

7 preoperational test program to the initial startup (ISU) program. ;

During a second hot functional test sequence' conducted in

November and December 1984, the MSIVs were successfully tested

in accordance with ISU-234A, " Main Steam Isolation Valves

Operability and Response Times. The MSIV8Vs continued to have

problems with the electro-hydraulic valve operator, resulting in

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a decision to place manual operators on the MSIVBVs and to

implement the appropriate procedure changes what will be

,,- W necessary to support manually operated MSIV8Vs. Final NRC

, acceptance of this test will be contingent upon a satisfactory

review of the completed Initial Startup Test package for

ISU-234A. 'This package will be inspected under the startup ,

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testing phase of the NRC light water reactor inspection program

(Inspection and Enforcement Manual Chapter 2514). This is an

Open Item 445/8506-01.

(2) 1CP-PT-64-01, "RPS Time Response Measurement," Revision 2.

Test Deficiency Report (TDR) 3799 was filed in the completed

test package with no corrective action-specified and no evidence

that it had been closed. The TDR was not addressed in the test

summary as an open TDR. The subject was opening times of.

containment spray valves 1-HV-4776 and 1-HV-4777. It appeared

that the valves were designed to open in less than 20 seconds.

The containment spray system design assumes it will be more than

117' seconds to preclude pump run-out. According to the

applicant's representatives, this problem was discovered during

the analysis of ICP-PT-64-01 data, but had no bearing on the

outcome of the test because the time responses of ICP-PT-64-01 ,

do not include actual valve operating time. The practice of 1

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having an open TDR in a completed test data package without a

JTG approved disposition does not meet the NRC inspection

criteria above. This is Open Item 445/8506-02.

Test Procedure Deviation (TPD) No. 18 changed two prerequisites

from lifting of leads to jumpering of contacts to prevent valve

1-HV-4168 from cycling during the test because p set of contacts

in the control circuit needed to remain closed (simulated by

jumper) rather than remain open (which would be simulated by

lifting leads). The " Reason for change" indicated, " Change ~

prerequisite to prevent cycling of value 1-HV-4168," instead of

indicating why, which was to correct a procedure error. In NRC

Inspection Report 50-445/85-02, the RRI commented that

inaccurately stated reasons for changes is a widespread problem.

This is another example. The applicant's action to correct this

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< _p roblem is already being tracked under Open Item 445/8502-02.

No' violations or deviations were identified.

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'As of this inspection the.preoperational testing phase of the NRC

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Light Water Reactor Inspection Program, Inspection and Enforcement

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- Manual Chapter.2513 is completed, with exception of any retests that

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e dispositioning previous preoperational test inspection findings. >

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Independent '-Inspection Findings

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a. " Deficiency Report Review

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The~RRI'selec'ted,'at random, an operations Deficiency Report (DR) to

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verify that appropriate corrective actions were being taken by TUGC0

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, operations management. The DR selected was DR 85-012, which pertained

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pump in accordance with Maintenance Action Request (MAR) 85-0292,

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which in turn implemented Mechanical Maintenance Instruction (MMI)

302, " Reactor Coolant Pump Seal Inspection."

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t Revision l'of MAR-85-0292 stated, " Steps of this procedure (MMI-302)

%.. 'may be worked out of sequence as long as the integrity of the job is

not affected;" According to the DR, the mechanics performed MMI-302,

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steps 5.2.7.11 before 5.2.7.9, and 5.2.7.8 after 5.2.7.9. This

resulted in damage to the lower seals, and particles from the broken

seal dropping into the upper RC pump housing.

.The recov'ery actions as documented on the DR appeared to be

. inadequate for the circumstances. Under " Corrective Action" the

Maintenance Engineer simply stated that the No. 1 lower seal ring

will'be replaced in accordance with MMI-302, paragraph 5.4.2. Under

" Preventive Action" the same engineer indicated, " Applicable

-maintenance personnel will be instructed'in the importance of working

instructions in sequence. This review will be documented in

accordance with MDA-106." The RRI noted the following specific

problems with this-scenario and the associated documentation:

(1) ' MAR-85-0292 was chacged to allow deviations-from MMI-302 with-

out an approved cha ge as required by Section 4.5.3 of MDA-201.

t- One of the caus_es o' the deficiency was failure of the people

, who approved-the change to recognize this. The disposition

entered on'DR.85-012 failed to address corrective actions to

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prevent recurrences of such improper reviews, which is in

violation.of J4ction 4.7 of STA-404, " Control of Deficiencies."

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(2) -DR 85-012 was initiated on 1/24/85, _The QC inspector on the job'

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verified cleanness of the RC pump oanulus using fibre optics on

January 31, 1985. There was no documentation-showing what

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< procedure, if any, was used to remove the broken seal ring to

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~ preclude further damage or breaches of RC system cleanliness.

Failure to provide such a procedures is contrary to the require

-ments of 10 CFR 50, Appendix B, Criterion V, and Section 13.1

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of the applicant's Operations Administrative Control and Quality

Assurance Plan.

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(3) Maintenance Department Administrative Procedure MDA-201,

T- '" Electrical and Mechanical Maintenance Procedures and

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Instructions," prescribes the formatting and revision control of

, instructions ~such as MMI-302. Step 4.3.7.3 of MDA-201 appears

- to leave it at the option of procedure writer to number the

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steps and the exact sequence of performing the maintenance, and

4 that if the exact sequence is,not essential, the writer has the

option to so state. On the other hand, step 4.5.3 requires a

e change to the procedure if the sequence of steps within a section

or subsection must be changed. When the NRC inspector began to

probe the details associated with DR 85-012, the applicant

recognized this problem and documented it on DR 85-078.

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(4); The NRC' inspector noted that DR_85-012 was reviewed by

MaintenanceiDepartment Personnel in accordance with MDA-106,

" Document-Review." One objective of_this procedure is to

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may learn from.the experience ~of others. The DR was only

disseminated to the two mechanics'who experienced the problem in

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'the'first place.' ,

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In summary, dodumentation m'ade availabl~e to the NRC inspector

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follow procedures'in accordance with.10'CFR'Part 50, Appendix B,.

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Control Plan. ~The Operations QA Program" failed to' ensure the

' adequacy of corre~ctive' actions ~ . The dissemination of lessons

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learned'to the" appropriate' personnel is considered an open item.

This is Open Item 445/8506-04.

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' Thisis(0 pen) violation:445/85b6-0'3.

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Fuel Storage-Inspect' ion / Fuel Inventory

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-inspection of the fuel storage facilities and an inventory of the

c- - ' Unit 1, Cycle 1 fuel and associated fuel bundle inserts.

The! storage facility inspection consisted of:

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~- o' Verification of security:and access control,

o- Verification of the cleanliness of the area,

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o Verification of the cleanliness of'each fuel element and storage

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cell and,

o Verification of the radiological controls.

< The fuel inventory consisted of:

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Verification that each fuel assembly and insert were accounted

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J ,o Verification that each fuel assembly and its insert were in

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their assigned storage cell and,

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t : o' . Verification that each assembly and its insert, when moved from

one' location to another, were logged.on a transfer sheet.

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-The fuel storage areas (both the new fuel storage and spent fuel

i - storage)-were. examined by the NRC inspectors.- The areas were found

. to 'be clean 'an'd free of foreign material, required' radiological

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controls were-in effect, and the-required security provisions were

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implemented.

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The NRC. inspectors al'so performed an inventory of all Unit 1, Cycle.1' l

nuclear fuel and fuel element inserts. The inventory was performed

by conducting:a " blind" ' accountability audit (1.e. , a blank-storage ,

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map was used.to record the contents of each storage cell in the new l

,a w,y fuel and spent fuel storage area). . The filled in. maps were then

b ti ~ compared to the applicant's records identifying the assigned storage-

3 . cell-' and . its contents ~. In addition, for each fuel movement since :

receipt.,the fuel transfer documents were examined. The inspectors

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found that each fuel element and its insert was in its assigned.

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Clocation and each fuel assembly movement was recorded on the required

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transfer documents.

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'No ; violations or deviations were . identified.

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..TMI Action Plan Item

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- Item II.E.1.1: required verification by. test, that the turbine driven

?; < auxiliary feed pump could operate a minimum of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 'without AC power.

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. cDuring t'he performance of ICP-PT-37-03, Revision 0, " Auxiliary Feedwater

. ~ Turbine Driven Pump", the pump was run for 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months with.no AC power, as '

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part.of.the 48-hour run. -During this 2-hour run there was no ventilation ~

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f to the room and the ventilation dampers were shut._ Thetemperatgreand

. humidity requirements of the ~2-hour portion of the gest were 104 F ~and

70%. The final temperature and humidity were 107.7 F and 100% humidity.' ,

s Gibbs and Hill' analyzed the deviation and concluded in GTN-65740 to use

as is. Since the conditions were more severe than-the test criteria, the' *

. -intent of the test was not lessened. The NRC. inspector concludes that the

< = 2-hour' test has met the: requirements of Item II.E.1.1.

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7 Thisiitem is closed.

5. Plant Tours

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i During this reporting period, the.SRRI and RRI conducted several

- inspection tours of. Unit 1. In addition to the general housekeeping

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. activities 1and general cleanliness of the facility, specific attention was

ogiven.to. areas where' safety-related equipment was instslied and where

activities ~were in' progress involving safety-related equipment. These

areas were-inspected to ensure that:

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(o Work in progress was being accomplished using approved procedures,

o Special precautions for protection of equipment were implemented, and

-additional ~ cleanliness,' requirements were being adhered to for

maintenance,' flushing, and welding activities.

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o. Installed safety-related equipment and components were being-

c protected and maintained to prevent damage and deterioration.

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iAlio during these' tours,,the SRRItand RRI. reviewed the control room and'

? shift: supervisors' log book.' Key items in.the log review were:

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' tests in. progress.

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: o' documentation.of problems which arise during operating shifts

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No deviations or violations were identified.

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.6. Plant Status.as of April-~30,21985

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.a. Unit 1Lis 99% complete'with 323 of 332 subsystems turned over to

operations custody. " Custody" means having immediate authority and

- responsibility for operational control of system or equipment.

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.The applicant has. accepted:305 of 332 subsystems for final

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b. Of _ the 199 preoperational tests, one is ;not yet completed on field

~ -p itesting,~and.27 are pending review and approval of completed data.

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3, ;There are no.further tests requiring NRC results evaluation review.

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The'following; items related to NRC' resident operations office

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. g ;c ' ~ i.9_inspection findingstoare opencompletion

confirm. pending applicant

for closure:action and NRC followup

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_Open. Items

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[ Action'isunderwaytocompletetheseitems. Closure will'be

m^' - documented'in future inspection reports. -

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Unit.'2 is 73% complete. The.preoperationalitest. program on systems-

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'1 - associated with NRC inspections.has not yet, started. .

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J 7.- . Exit-Meeting

An~ exit interview was conducted May 2, 1985, with applicant

i representatives identified in paragraph 1. During this interview, the

.a - *- ESRRIm reviewed the scope and discussed the inspection findings. The

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_ applicant acknowledged the-findings.

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ML20133E966

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